Research Data Retention and Access
The purposes of this policy are to (1) ensure compliance with federal requirements for retention of and access to research data under 2 CFR 215* Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, and (2) ensure adherence to commonly accepted practices for academic institutions advancing the research enterprise through dissemination of original research findings.
This policy applies to research data collected by all members of the College community (faculty, staff, students, and visiting scholars) under externally sponsored agreements.
Research data generated while individuals are pursuing research studies as faculty, staff, or students of Keene State College, and data generated by visiting scholars utilizing the facilities of Keene State College, are to be retained by the institution for a period of three (3) years after submission of the final report on the research project for which the data were collected, unless a longer period is specified by the external sponsor.**
The original research data will be retained by the senior investigator on behalf of the institution but must be returned to the institution upon request of an appropriate institutional official. Additionally, such data must be available to representatives of external sponsors of the research or designated governmental officials, when such access is appropriate. Such data must not be disposed of during the time period referenced above unless explicit written approval for such disposition is received from the Provost or his/her designee.
The definition of research data adopted by this policy is the broad definition found in 2 CFR 215:
Research data is defined as the recorded factual material commonly accepted in the scientific community as necessary to validate research findings.
This “recorded” material excludes physical objects (e.g., laboratory samples), as well as the following:
- Preliminary analyses
- Drafts of scientific papers
- Plans for future research
- Peer reviews
- Communications with colleagues
- Trade secrets, commercial information, materials necessary to be held confidential by a researcher until they are published, or similar information which is protected under law
- Personnel and medical information and similar information the disclosure of which would constitute a clearly unwarranted invasion of personal privacy, such as information that could be used to identify a particular person in a research study However, in regards to any specific sponsored research agreement, investigators are advised to review the award documentation carefully to identify any special data access or retention requirements.
Background, Rationale, and Guidance
Keene State College recognizes that the generators of data (faculty, staff, and students) often believe that they own the data produced in their laboratories or through their work, and that they have an interest in ensuring the data are used in an appropriate manner. At the same time, the College recognizes that it has a legal responsibility with regard to access and retention of data, particularly data generated under sponsored agreements.
Likewise, it is important that investigators be able to document the results of research, both for the sake of meeting legal requirements as well as for the more traditional reasons of publishing manuscripts, validating/replicating results, responding to questions regarding the veracity of findings, and establishing priority for patentable items, etc. Therefore, investigators are strongly encouraged to apply the 3-year data retention period to all research data, regardless of funding status, and to extend that retention period as necessary from the date of any publication of research findings.
Senior members of research teams have obligations to discuss the responsibilities of data management and retention with other members of the research team. As a matter of practice, original data should be left with the senior investigator when a student leaves the institution, but copies of the data, where feasible to do so, may be provided to the student.
When an investigator leaves the institution, (s)he must recognize that the institution must have access to the data produced through sponsored agreements. It is neither feasible nor desirable for the original research records to remain at the originating institution, but departing investigators must understand that they have an obligation to hold these data in trust for the institution and that such data must be returned to the institution if requested for a period of three (3) years after submission of the final report on the research project for which the data were collected, unless a longer period is specified by the external sponsor. Investigators leaving the institution shall sign a statement acknowledging and agreeing to these responsibilities as part of the exit process coordinated through the department of Human Resources.
Many federal agencies require a formal data management plan as part of the application for funding. Investigators needing assistance in planning for the management of their data are referred to the College’s Data Management Plan Guidance document.***
* Formerly OMB Circular A-110.
** The 3-year retention period is the minimum required. There are circumstances under which the research data records must be retained for a longer period, such as in the event of legal actions imposing a lengthier retention period, research misconduct proceedings (see Keene State College Research Misconduct Policy), or patent applications.
*** KSC’s Data Management Plan Guidance document can be found at: http://www.keene.edu/grants/
This policy was informed by the following sources, and we gratefully acknowledge the work of our professional colleagues:
- Council on Government Relations March 2006 document “Access to and retention of research data: Rights and responsibilities”
- Data Retention policy of Dartmouth College